office of chemical safety and pollution prevention ...€¦ · 6/11/2017 · triest ag group, inc....

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, DC 20460

Notification Label Revisions Requested v.20150904

OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION

November 6, 2017Mardel BelotinskyRegistration ManagerTriEst Ag Group, Inc.P.O. Box 448Greenville, NC 27835-0448

Subject: Notification per PRN 98-10 – Addition of referral statementsProduct Name: MBC-33EPA Registration Number: 87994-2Application Date: 10/12/2017Decision Number: 535072

Dear Ms. Belotinsky:

The Agency is in receipt of your Application for Pesticide Notification under Pesticide Registration Notice (PRN) 98-10 for the above referenced product. The Registration Division (RD) has conducted a review of this request for its applicability under PRN 98-10 and finds that the action requested falls within the scope of PRN 98-10. The label submitted with the application has been stamped “Notification” and will be placed in our records.

Should you wish to add/retain a reference to the company’s website on your label, then please be aware that the website becomes labeling under the Federal Insecticide Fungicide and Rodenticide Act and is subject to review by the Agency. If the website is false or misleading, the product would be misbranded and unlawful to sell or distribute under FIFRA section 12(a)(1)(E). 40 CFR 156.10(a)(5) list examples of statements EPA may consider false or misleading. In addition, regardless of whether a website is referenced on your product’s label, claims made on the website may not substantially differ from those claims approved through the registration process. Therefore, should the Agency find or if it is brought to our attention that a website contains false or misleading statements or claims substantially differing from the EPA approved registration, the website will be referred to the EPA’s Office of Enforcement and Compliance.

If you have any questions, you may contact Heather Garvie at 703-308-0034 or via email at [email protected].

Hope Johnson, Product Manager 21Fungicide BranchRegistration Division (7505P)Office of Pesticide Programs

MBC-33, EPA Reg. No. 87994-2, Draft Specimen Labeling, 2017 October 12, p. 1 Notes : Text in braces is administrative and will not appear on final labeling. Text in brackets is optional and may or may not appear on final labeling.}

Preplant Soil FumigantACTIVE INGREDIENTS: Methyl Bromide .............................67.0% Chloropicrin ...................................32.8%

OTHER INGREDIENTS: ........................ 0.2% TOTAL: ...................................................100.0% This product weighs 13.95 lbs./gal. @ 68ºF (20ºC).

For retail sale to and use by certified applicators or persons under their direct supervision and only for those uses covered by the certified applicator’s certification.

{Note : « Poison » will be printed in red.} Si Usted no entiende la etiqueta, busque a alguien para que se la explique a Usted en detalle.

(If you do not understand the label, find someone to explain it to you in detail.) IN ALL CASES OF OVEREXPOSURE, GET MEDICAL ATTENTION IMMEDIATELY.TAKE PERSON TO A DOCTOR OR TO AN EMERGENCY TREATMENT FACILITY.

Move person to fresh air.If person is not breathing, call 911 or an ambulance; then give artificial respiration, preferably by mouth-to-mouth, if possible.Call a poison control center or doctor for further treatment advice.Call a poison control center or doctor immediately for treatment advice. Have person sip a glass of water if able to swallow. Do not induce vomiting unless told to do so by a poison control center or doctor.Do not give anything by mouth to an unconscious person. Take off contaminated clothing.Rinse skin immediately with plenty of water for 15-20 minutes.Call a poison control center or doctor for treatment advice.Hold eyes open and rinse slowly and gently with water for 15-20 minutes.Remove contact lenses, if present, after the first 5 minutes; then continue rinsing eyes.Call a poison control center or doctor for treatment advice.

Note: Have the product container or label with you when calling a poison control center or doctor, or going for treatment.

Chemtrec 1-800-424-9300


[See side panel(s) for additional Precautionary Statements.] {AND/OR}[See attached label booklet for additional Precautionary Statements.] {AND/OR}

[See inside label booklet for additional Precautionary Statements.] {AND/OR} [See label booklet for additional Precautionary Statements and complete Directions for Use.] {AND/OR}

[See inside of label booklet for additional Precautionary Statements and complete Directions for Use.] {AND/OR}[See attached label booklet for complete Directions for Use.] {AND}

[Date of Labeling: {Insert stamped “accepted” date.}]

DANGER. Extremely hazardous liquid and vapor under pressure. Fatal if swallowed or inhaled. Corrosive. Causes skin burns and irreversible eye damage, which may have a delayed onset. Do not breathe vapor or gas. Inhalation may cause serious acute illness or delayed lung, nerve, or brain injury. Do not get in eyes, on skin or on clothing.

Chloropicrin may be irritating to the upper respiratory tract, and even at low levels can cause painful irritation to the eyes, producing tearing. If these symptoms occur, leave the fumigation area immediately.

Some materials that are chemical-resistant to this product are listed below. For more options, follow the instructions for Category H on the chemical-resistance category selection chart. PPE constructed of Saranex, neoprene, and chlorinated polyethylene provide short-term contact or splash protection against liquid in this product. Longer-term protection is provided by PPE constructed of Viton, Teflon, and EVAL barrier laminates (for example, responder suits manufactured by Life-Guard or Silvershield gloves manufactured by North). Where chemical-resistant materials are required, leather, canvas, or cotton materials offer no protection from this product and must not be worn as the sole article of protection when contact with this product is possible.

Wear long-sleeved shirt, long pants, shoes and socks. Not wear jewelry, goggles, tight clothing, chemical-resistant gloves, rubber protective clothing, or rubber boots when handling. Methyl bromide can be trapped inside clothing and cause skin injury.

Handlers with no potential for contact with liquid fumigant (e.g. shovelers) may wear cotton, leather, or other porous, non-chemical-resistant gloves. If such gloves are exposed to liquid

Early symptoms of overexposure to methyl bromide are dizziness, headache, nausea and vomiting, weakness, and collapse. Lung edema may develop in 2 to 48 hours after exposure, accompanied by cardiac irregularities; these effects are the usual cause of death. Repeated overexposures can result in blurred vision, staggering gait, and mental imbalance, with probable recovery after a period of no exposure. Blood bromide levels suggest the occurrence, but not the degree, of exposure. Treatment is symptomatic.


fumigant, they must immediately be removed and discarded.

Long-sleeved shirt and long pants, Chemical-resistant gloves, Chemical-resistant apron, Protective eyewear (Do NOT wear goggles), and Chemical-resistant footwear with socks.

In addition, when an air-purifying respirator is required under this label's Directions for Use,Protection for Handlers, Respiratory Protection and/or Stop Work Triggers section, handlers (including applicators) must wear a:

NIOSH-certified full-facepiece air-purifying respirator with cartridges certified by the manufacturer for protection from exposure to methyl bromide at concentrations up to 5 ppm (e.g., a 3M air-purifying respirator equipped with 3M Model 60928 Organic Vapor/Acid Gas/P100 cartridges).

IMPORTANT: A self-contained breathing apparatus (SCBA) is not permitted for routine handler tasks.

If responding to an emergency when corrective action is needed to reduce air concentrations to acceptable levels, wear an SCBA. Escape-only SCBA respirators must not be used by handlers for responding to emergencies. In addition wear PPE required for potential contact with liquid fumigant.

Users should: Wash hands before eating, drinking, chewing gum, using tobacco, or using the toilet. Remove clothing/PPE immediately if pesticide gets inside. Then wash thoroughly and put on clean clothing. Remove PPE immediately after handling this product. Wash the outside of gloves before removing. As soon as possible, wash thoroughly and change into clean clothing.

Follow manufacturer’s instructions for cleaning/maintaining PPE. If no such instructions for washables exist, use detergent and hot water. Keep and wash PPE separately from other laundry. Discard clothing and other absorbent materials that have been drenched or heavily contaminated with this product’s concentrate. Do not reuse them.


This pesticide is toxic to mammals and birds. Do not apply directly to water, or to areas where surface water is present or to intertidal areas below the mean high water mark. Do not contaminate water when disposing of equipment washwaters or rinsate. Methyl bromide and chloropicrin have certain properties and characteristics in common with chemicals that have been detected in groundwater (methyl bromide and chloropicrin are highly soluble in water and have low adsorption to soil). For untarped applications of methyl bromide and chloropicrin, leaching and runoff may occur if there is heavy rainfall after soil fumigation.

Do not use containers or application equipment made of magnesium, aluminum, or their alloys, as under certain conditions this fumigant may be severely corrosive to such metals. [See the Calibration, Set-up, Repair and Maintenance for Application Rigs section of this labeling for further requirements for application equipment.] Do not permit water to be used to clean the fumigant pressure system, as corrosion will result. Diesel oil is satisfactory for this purpose.

It is a violation of Federal law to use this product in a manner inconsistent with its labeling. Do not apply this product in a way that will contact workers or other persons, either directly or through drift. Only handlers may be in the application block from the start of the application until the entry restricted period ends, and in the buffer zone during the buffer zone period. For any requirements specific to your State or Tribe, consult the agency responsible for pesticide regulation.

Soil Fumigant Training Program: Certified applicator training that provides information on (1) how to correctly apply the fumigant, including how to comply with new label requirements; (2) how to protect handlers and bystanders; (3) how to determine buffer zone distances; (4) how to complete an FMP and the post-application summary; (5) how to determine when weather and other

Use this product only in accordance with its labeling and with the Worker Protection Standard, 40 CFR Part 170. This Standard contains requirements for the protection of agricultural workers on farms, forests, nurseries, and greenhouses, and handlers of agricultural pesticides. It contains requirements for training, decontamination, notification, and emergency assistance. The requirements in this box only apply to uses of this product that are covered by the Worker Protection Standard (WPS). No instructions elsewhere on this labeling relieve users from complying with the requirements of the WPS.

For the entry restricted period and notification requirements, see the Entry Restricted Period and Notification section of this labeling. PPE For Entry During the Entry-Restricted Period: PPE for entry that is permitted by this labeling is listed in the PersonalProtective Equipment (PPE) section of this labeling.


site-specific factors are not favorable for fumigant application; (6) how to comply with required GAPs and how to document compliance with GAPs in the FMP; and (7) how to develop and implement emergency response plans. Fumigant Safe Handling Information: Information that must be provided annually to handlers must include the following: (1) what fumigants are and how they work, (2) safe application and handling of soil fumigants, (3) air monitoring and respiratory protection requirements for handlers, (4) early signs and symptoms of exposure, (5) appropriate steps to take to mitigate exposures, (6) what to do in case of an emergency, and (7) how to report incidents. Application Block: Area within the perimeter of the fumigated portion of a field or greenhouse (including furrows, irrigation ditches, roadways). The perimeter of the application block is the border that connects the outermost edges of total area treated with the fumigant product. Application Rate: The ratio of fumigant mass applied compared to the soil surface area (e.g., lbs of product per acre). The application rate is expressed on this labeling in terms of either the “treated area application rate” or the “broadcast equivalent application rate.” The “treated area application rate” relates to only the rate of fumigant applied to the portion of the field that is fumigated (e.g., rate within the bed or strips). The “broadcast equivalent application rate” relates to the rate of fumigant applied within the entire perimeter of the application block. For bedded and strip applications, the “broadcast equivalent application rate” must be calculated to determine the buffer zone distance required by this labeling. Start of the Application: The time at which the fumigant is first delivered/dispensed into the soil in the application block. Application is Complete: The time at which the fumigant has stopped being delivered/dispensed into the soil and the soil has been sealed. Entry Restricted Period: This period begins at the start of the application and expires depending on the application method and if tarps are used when the tarps are perforated and removed. Entry into the application block during this period is only allowed for appropriately PPE-equipped handlers performing handling tasks. See the Entry Restricted Period and Notificationsection for additional information. Buffer Zone: An area established around the perimeter of each application block. The buffer zone must extend outward from the edge of the application block perimeter equally in all directions.Buffer Zone Period: Begins at the start of the application and lasts for a minimum of 48-hours after the application is complete. Non-handlers must be excluded from the buffer zone during the buffer zone period. Difficult to Evacuate Sites: Pre-K to Grade 12 schools, state-licensed daycare centers, nursing homes, assisted living facilities, hospitals, in-patient clinics, and prisons. Owner: Any person who has a present possessory interest (fee, leasehold, rental, or other) in an agricultural establishment. A person who has both leased such agricultural establishment to another person and granted that same person the right and full authority to manage and govern the use of such agricultural establishment is not an owner. See definition of “owner” in WPS (40 CFR §170.3). Roadway: Portion of a street or highway improved, designed or ordinarily used for vehicular travel, exclusive of the sidewalk or shoulder even if such sidewalk or shoulder is used by persons riding bicycles. In the event a highway includes two or more separated roadways, the term roadway shall refer to any such roadway separately. Representative Handling Task: For air monitoring, the locations and handler activities sampled must represent each handler's exposure occurring within the application block. For example, for


an application consisting of a seven-handler crew (1 tractor driver, 1 tractor co-pilot, 4 shovelers, and 1 certified applicator supervising) two breathing zone samples could be collected: one sample for the tractor co-pilot and one sample for a downwind shoveler. Results of previous sampling may indicate which tasks and locations are worst case and therefore representative of all handlers.

The use of this product is restricted to the methods described in this label. This product may only be used for the following: o Crops/uses at locations that at the time of the application qualify for exemptions under

the Montreal Protocol as identified in Table 1 [Maximum Rates for Crops/Uses with Critical Use Exemptions (CUEs)] of this labeling, or

o Crops/uses identified in Table 2 [Maximum Application Rates for Quarantine Uses] of this labeling.

Tarps must be used for all applications, except for deep shank orchard replant [California only] applications. The maximum application block sizes allowed are: o 100 acres for tarped bedded and broadcast applications o 40 acres for untarped deep applications (i.e., California orchard replant)

For Applications in California Only:

Use the buffer zone distances specified by the California Department of Pesticide Regulation, which are found at the website listed below. Additional California Department of Pesticide Regulation requirements must also be followed, including:

Additional tarp requirements Application time restrictions Additional buffer zone restrictions for overlapping buffer zones and credits Additional emergency preparedness and response requirements

The certified applicator must follow all California buffer zone requirements and California restrictions that are specified at: www.cdpr.ca.gov/chloropicrin.htm.

Soil-borne pests controlled include wireworms and nematodes, weed and grass seeds, Granville Wilt, Black Shank, and other diseases caused by certain species of Rhizoctonia, Pythium, Fusarium, and Phytophthora.

Comply with all local regulations and ordinances. Obtain an application permit from Agricultural Regulatory Agencies as required. Users should handle this fumigant in the open, with the operator 'upwind' from the container where there is good ventilation. When fumigating soil from a tractor, 5 gallons of water must be carried on the tractor and placed where it is readily accessible. In addition to water available on the tractor, at least 5


gallons additional water must be available from the service truck. This water must be potable and in containers marked "Decontamination water not to be used for drinking”. Keep pets, livestock, and other domestic animals out of the treated area during application and during tarp perforation and/or removal, if a tarp is used. Fumigation may temporarily raise the level of ammonia nitrogen and soluble salts in the soil. This is most likely to occur when heavy rates of fertilizer and fumigant are applied to soils that are either cold, wet, acid, or high in organic matter. To avoid injury to plant roots, fertilize as indicated by soil tests made after fumigation. To avoid ammonia injury and/or nitrate starvation to crops, avoid using fertilizers containing ammonia salts and use only fertilizers containing nitrates until after the crop is well established and the soil temperature is about 65 °F. Liming highly acid soils before fumigation stimulates nitrification and reduces the possibility of ammonia toxicity.

Any certified applicator supervising a soil fumigant application must have successfully completed one of the soil fumigant training programs listed on the following EPA website www.epa.gov/fumiganttraining for the active ingredient(s) in this product. The training must be completed in the time frames listed on the website. The FMP must document the date and location where the soil fumigant training program was completed.

The following activities are prohibited from being performed by anyone other than persons who have been appropriately trained and equipped as handlers in accordance with the requirements in WPS (40 CFR Part 170):

Monitoring fumigant air concentrations; Cleaning up fumigant spills (this does not include emergency personnel not associated with the application); Handling or disposing of fumigant containers; Cleaning, handling, adjusting, or repairing the parts of application equipment that may contain fumigant residues; and Performing any handling tasks as defined by the WPS (40 CFR 170).

The following activities are prohibited from being performed in the application block from the start of the application until the entry restricted period ends and in the buffer zone during the buffer zone period by anyone other than persons who have been appropriately trained and equipped as handlers in accordance with the requirements in WPS (40 CFR Part 170). (NOTE: persons repairing and monitoring tarps are considered handlers for the duration listed below). Prohibited activities (except for trained and equipped handlers) include:

Participating in the application as supervisors, loaders, drivers, tractor co-pilots, shovelers, cross ditchers, or as other direct application participants; Installing, repairing, operating, or removing irrigation equipment; Performing scouting, crop advising, or monitoring tasks; Installing, perforating (cutting, punching, slicing, poking), or removing tarps; and Repairing or monitoring tarps until 14 days after application is complete if tarps are not perforated and removed during those 14 days.


NOTE: see Tarp Perforation and/or Removal section on this labeling for requirements about when tarps are allowed to be perforated.

Handlers do not include local, state, or federal officials performing inspection, sampling, or other similar official duties.

For all applications, from the start of the application until the application is complete a certified applicator must be at the application block in the line of sight of the application and must directly supervise all persons performing handling activities. For handling activities that take place after the application is complete until the entry restricted period expires, the certified applicator is not required to be on-site, but must have communicated in a manner that can be understood by the site owner and handlers responsible for carrying out those activities the information necessary to comply with the label and procedures described in the FMP (e.g., emergency response plans and procedures).

IMPORTANT: this requirement does not override the requirements in the Worker Protection Standard for Agricultural Pesticides for information exchange between operators of agricultural establishments and commercial pesticide applicators.

The certified applicator must provide to each handler or confirm that within the past 12 months, each handler has received

in a manner that he/she can understand. will be provided where this product is purchased or at www.epa.gov/fumiganttraining.

For all handling tasks at least two handlers must be present. Exception: After the application is complete, only one trained handler is required to perform fumigant site monitoring tasks outside of the buffer zone.

The certified applicator supervising the application and the owner of the establishment where the application is taking place must make sure that all persons who are not trained and PPE-equipped and who are not performing one of the handling tasks as stated in this labeling are:

excluded from the application block during the entry restricted period, and excluded from the buffer zone during the buffer zone period (see buffer zone exemption for transit on roadways in Buffer Zone Requirements section).

Local, state, or federal officials performing inspection, sampling, or other similar official duties are not excluded from the application block or the buffer zone by this labeling. The certified applicator supervising the application and the owner of the establishment where the application is taking place are not authorized to, or responsible for, excluding those officials from the application block or the buffer zone.


The employer of any handler (as stated in this label) must make sure that all handlers are provided and correctly wear the required PPE. The PPE must be cleaned and maintained as required by the Worker Protection Standard for Agricultural Pesticides.

The employer of any handler must confirm that an air-purifying respirator and appropriate cartridges of the type specified in the PPE section of this labeling are immediately available for each handler who will wear one. At a minimum two handlers must have the appropriate air-purifying respirator and cartridges available (see Respirator Fit Testing, Medical Qualification, and Training section for additional requirements).

Exception: Air-purifying respirators do not need to be made available for handlers performing fumigant site monitoring tasks outside of the buffer zone.

Using a program that conforms to OSHA’s requirements (see 29 CFR Part 1910.134), employers must verify that any handler who uses a respirator is:

Fit-tested and fit-checked, Trained, and Examined by a qualified medical practitioner to ensure physical ability to safely wear the style of respirator to be worn. A qualified medical practitioner is a physician or other licensed health care professional who will evaluate the ability of a worker to wear a respirator. The initial evaluation consists of a questionnaire that asks about medical conditions (such as a heart condition) that would be problematic for respirator use. If concerns are identified, then additional evaluations, such as a physical exam, might be necessary. The initial evaluation must be done before respirator use begins. Handlers must be reexamined by a qualified medical practitioner if their health status or respirator style or use-conditions change. Upon request by local/state/federal/tribal enforcement personnel, employers must provide documentation demonstrating how they have complied with these requirements.

The following procedures must be followed to determine whether a full-facepiece air-purifying respirator is required or if operations must cease for any person performing a handling task (except for fumigant site monitoring outside of the buffer zone) as stated in this label.

If at any time any handler experiences sensory irritation (tearing, burning of the eyes or nose), then either: o A full-facepiece air-purifying respirator must be worn by all handlers who remain in the

application block or surrounding buffer zone, or o Operations must cease and handlers not wearing an air-purifying respirator must leave the

application block and surrounding buffer zone. Handlers can remove full-facepiece air-purifying respirators or resume operations if two consecutive breathing-zone samples taken at the handling site at least 15 minutes apart show that levels of methyl bromide have decreased to less than 1 ppm and levels of chloropicrin have decreased to less than 0.15 ppm, provided that handlers do not experience sensory irritation. During the collection of air samples, a full-facepiece air-purifying respirator must


be worn by the handler taking the air samples. Samples must be taken at the location where the irritation was first experienced. When using monitoring devices to monitor air concentration levels, a direct read detection device, such as an electronic device or a colorimetric device (e.g., Matheson-Kitagawa, Draeger, or Sensidyne) must be used. The devices must have sensitivity of at least 1 ppm for methyl bromide and 0.15 ppm for chloropicrin. Persons using direct read detection devices must follow the manufacturer’s directions. When breathing zone samples are required, they must be taken outside respiratory protection equipment and within a 10 inch radius of the handler's nose and mouth. When full-facepiece air-purifying respirators are worn, air monitoring samples must be collected at least every 2 hours in the breathing zone of a handler performing a representative handling task. If at any time: (1) a handler experiences sensory irritation when wearing a full-facepiece air-purifying respirator, or (2) a methyl bromide air sample is greater than 5 ppm or a chloropicrin air sample is greater than or equal to 1.5 ppm, then all handler activities must cease and handlers must be removed from the application block and surrounding buffer zone. Handlers can resume work activities without full-facepiece air-purifying respirators if two consecutive breathing-zone samples taken at the handling site at least 15 minutes apart show levels of methyl bromide have decreased to less than 1 ppm and levels of chloropicrin have decreased to less than 0.15 ppm, provided that handlers do not experience sensory irritation. During the collection of air samples a full-facepiece air-purifying respirator must be worn by the handler taking the air samples. Samples must be taken at the location where: (1) the irritation was first experienced, or (2) where sample(s) were greater than 5 ppm for methyl bromide or, (3) where sample(s) were greater than or equal to 1.5 ppm for chloropicrin. Handlers can resume work activities if all of the following conditions exist provided a full-facepiece air-purifying respirator is worn: o two consecutive breathing zone samples for methyl bromide taken at the handling site at

least 15 minutes apart each must be less than or equal to 5 ppm. o two consecutive breathing zone samples for chloropicrin taken at the handling site at least

15 minutes apart must be less than 1.5 ppm. o handlers do not experience sensory irritation while wearing the full-facepiece air-

purifying respirator, and o filter cartridges have been changed. O During the collection of air samples a full-facepiece air-purifying respirator must be worn

by the handler taking the air samples. Samples must be taken at the location where: (1) the irritation was first experienced, or (2) where sample(s) were greater than 5 ppm for methyl bromide or, (3) where sample(s) were greater than or equal to 1.5 ppm for chloropicrin.

IMPORTANT: Persons perforating, repairing, removing, and/or monitoring tarps are defined, within certain time limitations, as handlers (see Handlers section), and they must be provided the PPE and other protections for handlers as required on this labeling and in the Worker Protection Standard for Agricultural Pesticides.

Tarps must not be perforated until a minimum of 5 days (120 hours) have elapsed after the application is complete, unless a weather condition exists which necessitates early tarp perforation or removal (see Early Tarp Removal for Broadcast Applications Only and Early


Tarp Perforation during Flood Prevention Activities for Bedded Applications Only requirements). If tarps are perforated within 14 days after the application is complete, tarp removal must not begin until at least 2 hours after tarp perforation is complete and 2 consecutive methyl bromide air monitoring samples taken at least 15 minutes apart are less than 5 ppm. Air samples must be taken in the breathing zone of the handler. If the 2 consecutive air monitoring samples indicate that methyl bromide levels are:

o Less than 1 ppm and no sensory irritation is experienced, no respiratory protection is required to begin tarp removal.

o Between 1 ppm and 5 ppm, then an air-purifying respirator is required to begin tarp removal.

o See the Respiratory Protection and Stop Work Triggers and Personal Protective Equipment (PPE) sections for additional requirements.

If tarps are not perforated or removed within 14 days after the application is complete, planting or transplanting may take place while the tarps are being perforated. Each tarp panel used for broadcast application must be perforated. Tarps may be perforated manually ONLY for the following situations: o At the beginning of each row when a coulter blade (or other device which performs

similarly) is used on a motorized vehicle such as an ATV. o In fields that are 1 acre or less. o During flood prevention activities. In all other instances, tarps must be perforated (cut, punched, poked, or sliced) only by mechanical methods. Tarp perforation for broadcast applications must be completed before noon. For broadcast applications, tarps must not be perforated if rainfall is expected within 12 hours.Early Tarp Removal for Broadcast Applications Only: o Tarps may be removed before the required 5 days (120 hours) if adverse weather

conditions have compromised the integrity of the tarp, provided that the compromised tarp poses a safety hazard. Adverse weather includes high wind, hail, or storms that blow tarps off the field and create a hazard, e.g., tarps blowing into power lines and onto roads.A compromised tarp is a tarp that due to an adverse weather condition is no longer performing its intended function and is creating a hazard.

Early Tarp Perforation during Flood Prevention Activities for Bedded Applications Only: o Tarp perforation is allowed before the 5 days (120 hours) have elapsed. o Tarps must be immediately retucked and packed after soil removal. When perforating any tarp that qualifies for a 60% or greater reduction in buffer zone distance following broadcast shank applications: o All handlers must wear an air purifying respirator when perforating the tarp; and o Tarp removal must not begin until at least 2 hours after tarp perforation is complete and 2

consecutive air monitoring samples taken at least 15 minutes apart are less than 5 ppm. Air samples must be taken in the breathing zone of the handler. If the 2 consecutive air monitoring samples indicate that methyl bromide levels are:

Less than 1 ppm and no sensory irritation is experienced, no respiratory protection is required to begin tarp removal.


Between 1 ppm and 5 ppm, then an air-purifying respirator is required to begin tarp removal.

See the Respiratory Protection and Stop Work Triggers and Personal Protective Equipment (PPE) sections for additional requirements.

See www.tarpcredits.epa.gov for a list of tarps that have been tested and determined to qualify for buffer reduction credits.

Entry into the application block (including early entry that would otherwise be permitted under the WPS) by any person – other than a correctly trained and PPE-equipped handler who is performing a handling task listed on this labeling – is PROHIBITED - from the start of the application until:

5 days (120 hours) after the application is complete for untarped applications, or 5 days (120 hours) after the application is complete if tarps are not perforated and removed for at least 14 days after the application is complete, or 48 hours after tarp perforation is complete if tarps will be perforated within 14 days after the application is complete and will not be removed for at least 14 days after the application is complete, or tarp removal is completed if tarps are both perforated and removed less than 14 days after application is complete.

NOTES: See Tarp Perforation and/or Removal section on this labeling for requirements about when tarps are allowed to be perforated. If early tarp removal occurs for a broadcast application the entry restricted period is a minimum of 5 days after the application is complete. When listing application information for soil fumigant applications to comply with part 170.122 of the WPS, list the entry restricted period time frame in place of the REI.

Notify workers of the application by warning them orally and by posting Fumigant Treated Area signs. The signs must bear the skull and crossbones symbol and state: -- “DANGER/PELIGRO,” -- “Area under fumigation, DO NOT ENTER/NO ENTRE,”

“Methyl Bromide and Chloropicrin Fumigant in USE,”-- the date and time of fumigation, -- the date and time entry restricted period is over, -- “MBC-33”, and -- Name, address, and telephone number of the certified applicator in charge of the fumigation.

Post the Fumigant Treated Area sign instead of the WPS sign for this application, but follow all WPS requirements pertaining to location, legibility, text size, and sign size (40 CFR §170.120).

Post Fumigant Treated Area signs at all entrances to the application block no sooner than 24 hours prior to application.


Fumigant Treated Area signs must remain posted for no less than the duration of the entry restricted period.

Fumigant Treated Area signs must be removed within 3 days after the end of the entry restricted period.

The following GAPs must be followed during all fumigant applications.

(required for all applications, except for deep shank orchard replant [California only] applications)

Tarps must be installed immediately after the fumigant is applied to the soil for bedded or broadcast applications. A written tarp plan must be developed and included in the FMP. Once a tarp is perforated, the application is no longer considered tarped.

To determine if unfavorable weather conditions exist or are predicted (see IdentifyingUnfavorable Weather Conditions section) and whether application should proceed, the National Weather Service weather forecast must be checked by the certified applicator supervising the application: o on the day of, but prior to the start of the application, and o on a daily basis during the application if the time period from the start of the application

until the application is complete is greater than 24 hours.Do not apply if an air stagnation advisory issued by the National Weather Service is in effect for the area in which the application is planned, during the application, or the 48 hours after the application is complete. Do not apply if light wind conditions (< 2 mph) are forecast to persist for more than 18 consecutive hours from the time the application starts until 48 hours after the application is complete. Detailed National Weather Service forecasts for local weather conditions, wind speed, and air stagnation advisories may be obtained on-line at: http://www.nws.noaa.gov, on NOAA weather radio, or by contacting your local National Weather Service Forecasting Office.

Identifying Unfavorable Weather Conditions Unfavorable weather conditions block upward movement of air, which results in trapping fumigant vapors near the ground. The resulting air mass can move off-site in unpredictable directions. These conditions typically exist within an hour prior to sunset and continue past sunrise and may persist as late as noontime. Unfavorable conditions are common on nights with limited cloud cover and light to no wind and their presence can be indicated by ground fog or smog and can also be identified by smoke from a ground source that flattens out below a ceiling layer and moves laterally in a concentrated cloud.


The maximum soil temperature at the depth of injection must not exceed 90 °F at the beginning of the application. If air temperatures have been above 100 °F in any of the three days prior to the start of the application, then soil temperature must be measured and recorded in the FMP. Record temperature measurements at the application depth or 12 inches, whichever is shallower.

The soil must be moist 9 inches below the surface. The amount of moisture needed in this zone will vary according to soil type. Surface soil generally dries rapidly and must not be considered in this determination. Soil moisture must be determined using one of the following methods: o the USDA Feel and Appearance Method for testing (see below), or o an instrument, such as a tensiometer. Available water capacity must be equal to or greater than 50% for shank applications. If there is less than 50% available water capacity 9 inches below the surface, the soil moisture must be adjusted. If irrigation is not available and there is adequate soil moisture below 9 inches, soil moisture can be adjusted by discing or plowing before the start of the application.To conserve existing soil moisture, pretreatment irrigation or pretreatment tillage should be done as close to the time of application as possible. Measure soil moisture at a depth of 9 inches at either end of the field, no more than 48 hours prior to the start of the application.

The USDA Feel and Appearance Method for estimating soil moisture as appropriate for the soil texture:

For textured soils (fine sand and loamy fine sand), the soil is moist enough (50 to 75 % available water capacity) to form a weak ball with loose and clustered sand grains on fingers, darkened color, moderate water staining on fingers, will not ribbon. For textured soils (sandy loam and fine sandy loam), the soil is moist enough (50 to 75 % available water capacity) to form a ball with defined finger marks, very light soil/water staining on fingers, darkened color will not stick. For textured soils (sandy clay loam, loam, and silt loam), the soil is moist enough (50 to 75 % available water capacity) to form a ball, very light staining on fingers, darkened color, pliable, and forms a weak ribbon between the thumb and forefinger. For textured soils (clay, clay loam, and silty clay loam), the soil is moist enough (50 to 75 % available water capacity) to form a smooth ball with defined finger marks, light soil/water staining on fingers, ribbons between thumb and forefinger. For , soil moisture content in the lightest textured (most sandy) areas must comply with this soil moisture requirement. Whenever possible, the field should be divided into areas of similar soil texture and the soil moisture of each area should be adjusted as needed. Coarser textured soils can be fumigated under conditions of higher soil moisture than finer textured soils; however, if the soil moisture is too high, fumigant movement will be retarded and effectiveness of the treatment will be reduced. Previous and/or local experience with the soil to be treated or the crop to be planted can often serve as a guide to conditions that will be acceptable. If there is uncertainty in determining the soil moisture content of the area to be treated, a local extension service agent, soil


conservationist, or pest control advisor (agriculture consultant) should be consulted for assistance.

Soil must be properly prepared and at the surface be generally free of large clods. The area to be fumigated must be tilled to a depth of 5 to 8 inches. Field trash must be properly managed. Residue from a previous crop must be worked into the soil to allow for decomposition prior to the start of the application. Little or no crop residue shall be present on the soil surface. Crop residue that is present must not interfere with the soil seal. Removing the crop residue prior to the start of the application is important to limit the natural “chimneys” that occur in the soil when crop residue is present. These “chimneys” allow the soil fumigants to move through the soil quickly and escape into the atmosphere. This may create potentially harmful conditions for workers and bystanders and limit the efficacy of the fumigant. However, crop residue on the field serves to prevent soil erosion from both wind and water and is an important consideration. To accommodate erosion control, fumigant efficacy, and human health protection, clear fields of crop residue as close to the start of the application as possible to limit the length of time that the soil would be exposed to potentially erosive weather conditions.

For Broadcast Untarped Applications (CA orchard replant only): Use a disc or similar equipment to uniformly mix the soil to at least a depth of 3 to 4 inches to eliminate the chisel or plow traces. Following elimination of the chisel trace, the soil surface must be compacted with a cultipacker, ring roller, and roller in combination with tillage equipment. For Bedded Applications: Preformed beds must be sealed by disruption of the chisel trace using press sealers, bed shapers, cultipackers, or by re-shaping (e.g., relisting, lifting and replacing) the beds immediately following injection. Beds formed at the time of application must be sealed by disrupting the chisel trace using press sealers or bed shapers. For Tarped-Broadcast and Tarped-Bedded Applications: The use of a tarp does not eliminate the need to minimize chisel traces prior to application of the tarp, such as by using a Noble plow or other injection shank that disrupts the chisel traces.

In addition to the GAPs required for all soil fumigation applications, the following GAPs apply for injection applications:

Trash pulled by the shanks to the ends of the field must be covered with tarp, or soil, depending on the application method before making the turn for the next pass.

For Tarped-Broadcast and Tarped-Bedded Applications: The injection point must be a minimum of 8 inches from the nearest final soil/air interface. For tarped bedded applications, the injection depth must not be deeper than the lowest point of the tarp (i.e., the lowest point of the tuck).


For Untarped-Broadcast Applications (CA orchard replant only): The injection point must be a minimum of 18 inches from the nearest final soil/air interface. Apply MBC-33 Soil Fumigant with chisel equipment. The shank spacing should be equal to the application depth, but may be up to 1½ times the application depth, not to exceed 24 inches. When applying MBC-33 Soil Fumigant with a Noble plow, use an outlet spacing of 9-12 inches along the sweeps.

Do not apply or allow fumigant to spill onto the soil surface. For each injection line either have a check valve located as close as possible to the final injection point or drain/purge the line of any remaining fumigant prior to lifting injection shanks from the ground. Do not lift injection shanks from the soil until the shut-off valve has been closed and the fumigant has been depressurized (passively drained) or purged (actively forced out via air compressor) from the system.

Brass, carbon steel, or stainless steel fittings must be used throughout. Polyethylene tubing, polypropylene tubing, Teflon® tubing or Teflon® -lined steel braided tubing must be used for all low pressure lines, drain lines, and compressed gas or air pressure lines. All other tubing must be Teflon® -lined steel braided. Galvanized, PVC, nylon, or aluminum pipe fittings must not be used. All rigs must include a filter to remove any particulates from the fumigant and for pressurized systems a check valve to prevent backflow of the fumigant into the pressurizing cylinder or the compressed air system. Rigs must include a flow meter or a constant pressure system with orifice plates to ensure the proper amount of fumigant is applied. To prevent the backflow of fumigant into the compressed gas cylinder (e.g., nitrogen, other inert gas, compressed air), if used, applicators must: o Ensure that positive pressure is maintained in the compressed gas cylinder at not less than

200 psi during the entire time it is connected to the application rig, if a compressed gas cylinder is used. (This is not required for a compressed air system that is part of the application rig because if the compressor system fails the application rig will not be operable.)

o Ensure that application rigs are equipped with properly functioning check valves between the compressed gas cylinder or compressed air system and the fumigant cylinder. The check valve is best placed on the outlet side of the pressure regulator, and is oriented to only allow compressed gas to flow out of the cylinder or compressed air out of the compressed air system.

o A pressure relief valve must be installed between the regulator and the check valve to ensure a regulator failure does not overpressurize the fumigant cylinder.

o Always pressurize the system with compressed gas or by use of a compressed air system before opening the fumigant cylinder valve.

Before using a fumigation rig for the first time or when preparing it for use after storage, the operator must check the following items carefully: o Check the filter, and clean or replace the filter element as required. o Check all tubes and chisels to make sure they are free of debris and obstructions.


o Check and clean the orifice plates and screen checks, if installed. o Pressurize the system with compressed gas or compressed air, and check all fittings,

valves, and connections for leaks using soap solution. Install the fumigant cylinder, and connect and secure all tubing. Slowly open the compressed gas or compressed air valve, and increase the pressure to the desired level. Slowly open the fumigant cylinder valve, always watching for leaks. When the application is complete, close the fumigant cylinder valve and blow residual fumigant out of the fumigant lines into the soil using compressed gas or compressed air. If the rig uses a centrifugal pump instead of compressed gas to inject fumigant into the soil, you may clear residual fumigant from the fumigant lines using an application wand connected to the system’s low point via a drain hose. Place the wand in the soil until all residual fumigant has drained from the system. The wand and drain hose must be free of dirt to allow proper drainage. At the end of the application season, disconnect all fumigant cylinders from the application rig. At the end of the season, seal all tubing openings with tape to prevent the entry of insects and dirt. Application equipment must be calibrated and all control systems must be working properly. Proper calibration is essential for application equipment to deliver the correct amount of fumigant uniformly to the soil. Refer to the manufacturer’s instructions on how to calibrate your equipment. Usually the equipment manufacturer, fumigant dealer, or Cooperative Extension Service can provide assistance.

Planting or transplanting must not occur until at least 14 days after the application is complete. If odors of the fumigant persist beyond this 14 day period (and after tarps are perforated and/or removed), delay planting and disc or plow the soil to help aeration. SeeTarp Perforation and/or Removal section on this labeling for further requirements.

During the application keep all doors, vents, and windows to the outside open, and keep all fans or mechanical ventilation systems running within the greenhouse. Seal gaps through which gases could leak into adjacent enclosed areas.


1

Eggplant 522 Cucurbits (including muskmelons, cantaloupe, watermelon, cucumber, squash, pumpkin, and gourds)

373

Forest Nursery Seedlings 447 sandy soils 597 clay loam soils

with less than 30% clay Orchard Nursery Seedlings (raspberry, deciduous trees, roses)Strawberry Nurseries Orchard Replant2 (walnuts, almonds, stone fruit, table and raisin grapes, wine grapes)

447

Ornamentals 298 Peppers 298 Strawberry Fruit3 261 California3

358 Eastern US Sweet Potato Slips 522 Tomato (grown for fresh market) 358

1Do not exceed specified maximum application rates in Table 1. Row, bed or strip applications may be made at the treated acre application rates, but their broadcast equivalent rates will be proportionately less per acre depending on the spacing and width of treatment in the row, bed or strip.2The maximum rate to control infestation of Oak Root Fungus (Armillaria mellea) and/or endoparasitic nematodes such as root-knot (Meloidogyne spp.), dagger (Xiphinema spp.), ring (Criconemoides spp.), lesion (Pratylenchus spp.), and pin (Paratylenchus spp.) nematodes is 400 lbs methyl bromide/acre (cannot exceed 597 lbs MBC-33 per acre). Documentation of the pest(s) must be included in the site-specific fumigation management plan. 3The maximum rate to control infestation of Fusarium, Macrophomina, and/or Verticillium is 350 lbs MBC-33 per treated acre. Documentation of these pest(s) must be included in the site-specific fumigation management plan.

This product may be used as part of a quarantine program as described below.

Quarantine applications with respect to methyl bromide, are treatments to prevent the introduction, establishment and/or spread of quarantine pests (including diseases), or to ensure their official control, where: (i) Official control is that performed by, or authorized by, a national (including state, tribal or local) plant, animal or environmental protection or health authority; (ii) quarantine pests are pests of potential importance to the areas endangered thereby and not yet present there, or present but not widely distributed and being officially controlled. This definition excludes treatments of commodities not entering or leaving the United States or any State (or political subdivision thereof).


This product may be used as a soil fumigant at any crop or non-crop site as part of a quarantine program established by the United States Department of Agriculture-Animal and Plant Health Inspection Service (USDA-APHIS) under the Plant Protection Act (7 U.S.C. 7701 et seq.). Limitations including but not limited to application rates and methods and crops and cropping practices must be in accordance with those established by the USDA-APHIS quarantine program.

Quarantine use of methyl bromide is restricted to fields used for the production of plant propagative material listed below and unplanted areas immediately adjacent thereto, where all production from the treated fields will be shipped to areas where a plant regulatory authority requires the source or the incoming material to be free of quarantine pests or be accompanied by a certificate issued by a plant regulatory official.

Conifer and hardwood seedling for reforestation, Christmas tree seedlings

Roses, strawberry transplants, sweet potato slips, caneberry and blueberry nursery stock , fruit and nut trees, garlic transplants, onion transplants, vineyard stock, seed potato, tobacco seed beds, food crop transplants, and other wild or cultivated trees, shrubs, vines and forbs.

Caladiums, chrysanthemums, flower bulbs, flowering plants, ornamental grasses, rhizomes, shrubs, trees, and other perennials and annuals.

For interstate and intrastate shipments to areas that require fumigation with methyl bromide to meet quarantine/phytosanitary requirements The maximum application rate for quarantine uses shall be 597 lbs of MBC-33 per acre, or less if specified in the applicable quarantine/phytosanitary requirements.

The U.S. Federal, state, or local plant, animal, environmental protection or health authority requiring the quarantine application and the particular quarantine/phytosanitary requirement must be identified in the site-specific fumigant management plan. Additionally, the requirement for the treatment (e.g., the State or Federal law) must be listed in the site-specific fumigant management plan.


To calculate the broadcast equivalent rate for bedded or strip applications the following information is needed:

pounds of product per treated acre strip or bed bottom width (inches) center-to-center row spacing (inches)application block size (acres)

Pounds of product is the ratio of total amount of product applied to the size of the

(e.g., the rate of product applied in the bed). For bedded or strip applications, the is the summation of the area (i.e., length x width) of each treated bed bottom or strip that is located within the application block as shown by the black areas in Figure 1 (e.g., black areas are 0.6A or 60% of the area within the application block). The area of the space between the beds/strips is not factored in the total area treated. The is the acreage within the perimeter of the fumigated portion of a field (including furrows, irrigation ditches, roadways).The perimeter of the application block is the border that connects the outermost edges of total area treated with the fumigant product.


The “broadcast equivalent rate” must be calculated with the following formula:

Broadcast equivalent rate (pounds product/acre) =

strip or bed bottom width (inches)

x

pounds of product/

treated acre applied in the strip or bed

The bed width must be measured from the bottom of the bed. The center-to-center row spacing must be calculated as shown in Figure 2. If there are any ditches, waterways, drive rows and other areas that are not fumigated that are in the application block, multiply the above broadcast equivalent equation by

A sample calculation is provided below.


Assumptions: o Application method is shank bedded o Bed width is 30 inches (measured at the bottom of bed) o Center-to-center row spacing is 60 inches o 200 pounds of product per treated acre is applied in the beds o Total application block size is 10 acres o Ditch in the middle of application block is 0.25 acres o Area of beds + row spacing is 9.75 acres


A buffer zone must be established for every fumigant application. The following describes the buffer zone requirements:

The buffer zone must extend outward from the edge of the application block perimeter equally in all directions. All non-handlers, including field workers, residents, pedestrians, and other bystanders, must be excluded from the buffer zone during the buffer zone period except for transit (see Bufferzone exemption for transit on roadways section). o Local, state, or federal officials performing inspection, sampling, or other similar official

duties are not excluded from the application block or the buffer zone by this labeling. The certified applicator supervising the application and the owner of the establishment where the application is taking place are not authorized to, or responsible for, excluding those officials from the application block or the buffer zone.

For broadcast shank applications using any tarp that qualifies for a 60% or greater reduction in buffer zone distance: 1. The buffer zone period begins at the start of the application and ends after the tarps have

been removed from the application block. 2. As an alternative to (1) above, two buffer zone periods may be established where the first

buffer zone period begins at the start of the application and lasts for a minimum of 48 hours after the application is complete. The second buffer zone period begins when the tarps are perforated and ends after the tarps have been removed from the application block.

For all other applications, the buffer zone period begins at the start of the application and lasts for a minimum of 48 hours after the application is complete.

See www.tarpcredits.epa.gov for a list of tarps that have been tested and determined to qualify for buffer reduction credits.

Buffer zone proximity Before the start of application, the certified applicator must determine whether their buffer zone will overlap any methyl bromide buffer zone(s). To reduce the potential for off-site movement from multiple fumigated fields, buffer zones from multiple methyl bromide application blocks must not overlap :1. A minimum of 12 hours have elapsed from the time the earlier application(s) is complete

until the start of the later application, and 2. Fumigant Site Monitoring or Response Information for Neighbors has been implemented

if there are any residences or businesses within 300 feet of any of the buffer zones.

Structures under the control of the owner of the application block Buffer zones must not include buildings used for storage (e.g., sheds, barns, garages),


1. The storage buildings are not occupied during the buffer zone period, and 2. The storage buildings do not share a common wall with an occupied structure.

Areas not under the control of the owner of the application block o Buffer zones must not include residential areas (e.g., employee housing, private property),

buildings (e.g., commercial, industrial), outdoor residential areas (e.g., lawns, gardens, play areas) and other areas that people may occupy, ,1. The occupants provide written agreement prior to the application that they will

voluntarily vacate the buffer zone during the entire buffer zone period, and 2. Reentry by occupants and other non-handlers must not occur until,

The buffer zone period has ended, and Sensory irritation is not experienced upon re-entry.

o Buffer zones must not include agricultural areas owned and/or operated by persons other than the owner of the application block, ,1. The owner of the application block can ensure that the buffer zone will not overlap with a

methyl bromide buffer zone from any other property owners, except as provided in the Buffer Zone Proximity section, and

2. The owner of the other property provides written agreement to the applicator that they, their employees, and other persons will stay out of the buffer zone during the entire buffer zone period.

o Buffer zones must not include roadways and rights of way 1. The area is not occupied during the buffer zone period, and 2. Entry by non-handlers is prohibited during the buffer zone period.

Buffer zone exemption for transit on roadways Vehicular and bicycle traffic on public and private roadways through the buffer zone is permitted. (NOTE: Buffer zones are not permitted to include bus stops or other locations where persons wait for public transit.)

o For all other publicly owned and/or operated areas such as parks, sidewalks, permanent walking paths, playgrounds, and athletic fields, buffer zones must not include these areas

1. The area is not occupied during the buffer zone period, 2. Entry by non-handlers is prohibited during the buffer zone period, and 3. Written permission to include the public area in the buffer zone is granted by the

appropriate state and/or local authorities responsible for management and operation of the area.

Certified applicators must comply with all local laws and regulations.

See the Posting section for additional requirements that may apply.

Buffer zone distances must be calculated using the application rate and the size of the application block.

Applications in California: Where a Restricted Materials Permit is required for soil fumigation [pursuant to citation for California law], use the buffer zone distance for the application block that is specified in the


Restricted Materials Permit issued by the County Agricultural Commissioner, provided that the buffer zone distance is equal to or greater than the buffer zones distance specified in the December 8, 2004 California Department of Pesticide Regulation Methyl Bromide Field Fumigation Guidance Manual (see http://www.cdpr.ca.gov/docs/county/training/methbrom/mebrman.pdf ) in accordance with Title 3, Division 6, Subchapter 4 of the California Code of Regulations in effect on January 1, 2011.

In all other cases, determine the buffer zone distance for your application using the directions under Applications outside California.

Applications outside California: Buffer zone distances must be based on look-up tables in this labeling (25 feet is the minimum distance regardless of site-specific application parameters). If after applying all applicable buffer zone credits the buffer zone is greater than ½ mile (2,640 ft), then the application is prohibited. For all other applications, Tables 3, 4, or 5, as appropriate for the method of application must be used to determine the minimum buffer distances. Round up to the nearest rate and block size, where applicable. Applications are prohibited for rates or block sizes that exceed what is presented in the buffer zone tables.


1 2 3 4 5 6 7 8 9 10 15 20 25 30 35 40 50 60 70 80 90 10037 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 2545 25 25 25 25 25 25 25 25 25 25 25 25 25 25 28 31 34 38 41 44 45 4752 25 25 25 25 25 25 25 25 25 25 25 25 25 25 31 38 44 50 56 63 66 6960 25 25 25 25 25 25 25 25 25 25 25 25 25 25 34 44 53 63 72 81 86 9167 25 25 25 25 25 25 25 25 25 25 25 25 25 25 38 50 63 75 88 100 106 11375 25 25 25 25 25 25 25 25 25 25 25 25 25 25 41 56 72 88 103 119 127 13482 25 25 25 25 25 25 25 25 25 25 25 25 25 25 44 63 81 100 119 138 147 15690 25 25 25 25 25 25 25 25 25 25 25 25 25 25 47 69 91 113 134 156 167 17897 25 25 25 25 25 25 25 25 25 25 25 25 25 25 50 75 100 125 150 175 188 200

104 25 27 28 30 31 33 35 36 38 40 46 52 56 60 86 113 144 175 204 233 249 265112 25 28 31 34 38 41 44 48 51 54 67 79 88 96 123 150 188 225 258 292 311 331119 25 30 34 39 44 49 54 59 64 69 88 106 119 131 159 188 231 275 313 350 373 396127 25 31 38 44 50 57 63 70 77 83 108 133 150 167 196 225 275 325 367 408 435 462134 25 33 41 48 56 65 73 81 90 98 129 160 181 202 232 263 319 375 421 467 497 527142 25 34 44 53 63 73 83 93 103 113 150 188 213 238 269 300 363 425 475 525 559 593149 25 36 47 58 69 80 92 104 115 127 171 215 244 273 305 338 406 475 529 583 621 658157 25 38 50 63 75 88 102 115 128 142 192 242 275 308 342 375 450 525 583 642 683 723164 25 39 53 67 81 96 111 126 141 156 213 269 306 344 378 413 494 575 638 700 744 789172 25 41 56 72 88 104 121 138 154 171 233 296 338 379 415 450 538 625 692 758 806 854179 25 42 59 77 94 112 130 149 167 185 254 323 369 415 451 488 581 675 746 817 868 920187 25 44 63 81 100 120 140 160 180 200 275 350 400 450 488 525 625 725 800 875 930 985194 27 48 69 90 112 133 154 175 196 217 295 373 427 481 521 562 665 768 848 927 987 1047201 29 52 76 100 123 145 168 190 212 235 315 396 454 512 555 598 705 811 895 979 1044 1109209 31 57 83 109 135 158 182 205 228 252 336 419 481 542 588 635 744 854 943 1031 1101 1171216 33 61 89 118 146 171 195 220 245 269 356 442 508 573 622 671 784 897 990 1083 1158 1233224 35 65 96 127 158 183 209 235 261 287 376 465 535 604 656 708 824 940 1038 1135 1215 1295231 37 70 103 136 169 196 223 250 277 304 396 488 562 635 689 744 864 983 1085 1187 1272 1357239 38 74 110 145 181 209 237 265 293 321 416 512 588 665 723 781 904 1027 1133 1238 1328 1418246 40 78 116 154 192 222 251 280 309 338 437 535 615 696 757 817 943 1070 1180 1290 1385 1480254 42 83 123 163 204 234 265 295 325 356 457 558 642 727 790 854 983 1113 1228 1342 1442 1542261 44 87 130 173 215 247 278 310 342 373 477 581 669 758 824 890 1023 1156 1275 1394 1499 1604269 46 91 137 182 227 260 292 325 358 390 497 604 696 788 858 927 1063 1199 1323 1446 1556 1666276 48 96 143 191 238 272 306 340 374 408 517 627 723 819 891 963 1103 1242 1370 1498 1613 1728284 50 100 150 200 250 285 320 355 390 425 538 650 750 850 925 1000 1143 1285 1418 1550 1670 1790291 56 108 159 211 263 298 333 369 404 440 556 673 776 879 957 1035 1185 1334 1471 1608 1735 1861299 63 116 169 222 275 311 347 383 418 454 575 696 802 908 990 1071 1227 1383 1525 1667 1799 1932306 69 123 178 233 288 324 360 396 433 469 594 719 828 938 1022 1106 1269 1433 1579 1725 1864 2003313 75 131 188 244 300 337 373 410 447 483 613 742 854 967 1054 1142 1312 1482 1633 1783 1928 2073321 81 139 197 255 313 350 387 424 461 498 631 765 880 996 1086 1177 1354 1531 1686 1842 1993 2144328 88 147 206 266 325 363 400 438 475 513 650 788 906 1025 1119 1213 1396 1580 1740 1900 2058 2215336 94 155 216 277 338 375 413 451 489 527 669 810 932 1054 1151 1248 1439 1629 1794 1958 2122 2286343 100 163 225 288 350 388 427 465 503 542 688 833 958 1083 1183 1283 1481 1678 1848 2017 2187 2357351 106 170 234 298 363 401 440 479 518 556 706 856 984 1113 1216 1319 1523 1728 1901 2075 2251 2428358 113 178 244 309 375 414 453 493 532 571 725 879 1010 1142 1248 1354 1565 1777 1955 2133 2316 2498366 119 186 253 320 388 427 467 506 546 585 744 902 1036 1171 1280 1390 1608 1826 2009 2192 2380 2569373 125 194 263 331 400 440 480 520 560 600 763 925 1063 1200 1313 1425 1650 1875 2063 2250 2445 2640

Table 3. Tarped Bedded Buffer Zone Distances (feet)Application Block Size (Acres)

Bro

adca

st E

quiv

alen

t App

licat

ion

Rate

(lbs

pro

duct

/Acr

es)


1 2 3 4 5 6 7 8 9 10 15 20 25 30 35 40 50 60 70 80 90 10067 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 2582 25 25 25 25 25 25 25 25 25 25 33 42 48 54 60 67 74 81 89 96 102 10897 25 25 25 25 25 25 25 25 25 25 42 58 71 83 96 108 123 138 152 167 179 192

112 25 25 25 25 25 25 25 25 25 25 50 75 94 113 131 150 172 194 216 238 256 275127 25 25 25 25 25 25 25 25 25 25 58 92 117 142 167 192 221 250 279 308 333 358142 25 25 25 25 25 25 25 25 25 25 67 108 140 171 202 233 270 306 343 379 410 442157 25 25 25 25 25 25 25 25 25 25 75 125 163 200 238 275 319 363 406 450 488 525172 25 30 34 39 43 46 49 51 54 57 114 170 213 255 297 339 391 443 495 548 592 636187 25 34 43 52 61 67 72 78 83 89 152 216 263 309 356 402 463 524 585 645 697 748201 25 39 52 66 80 88 96 104 112 120 191 261 313 364 415 466 535 605 674 743 801 859216 25 43 61 80 98 109 120 130 141 152 230 307 363 418 474 530 607 685 763 841 906 970231 25 48 70 93 116 130 143 157 170 184 268 352 413 473 533 593 680 766 852 939 1010 1082246 25 52 80 107 134 150 167 183 200 216 307 398 463 527 592 657 752 847 941 1036 1115 1193261 25 57 89 120 152 171 190 210 229 248 345 443 513 582 651 720 824 927 1031 1134 1219 1305276 25 61 98 134 170 192 214 236 258 280 384 489 563 636 710 784 896 1008 1120 1232 1324 1416291 25 66 107 148 189 213 238 262 287 311 423 534 613 691 769 848 968 1089 1209 1330 1428 1527306 25 70 116 161 207 234 261 289 316 343 461 580 663 745 828 911 1040 1169 1298 1427 1533 1639321 25 75 125 175 225 255 285 315 345 375 500 625 713 800 888 975 1113 1250 1388 1525 1638 1750336 36 88 140 191 243 275 307 339 370 402 533 664 756 849 941 1034 1181 1327 1474 1620 1742 1864351 48 101 155 208 261 295 329 362 396 430 566 702 800 898 995 1093 1249 1405 1560 1716 1847 1977366 59 114 169 224 280 315 350 386 421 457 599 741 844 947 1049 1152 1317 1482 1647 1811 1951 2091381 70 127 184 241 298 335 372 410 447 484 632 780 888 995 1103 1211 1385 1559 1733 1907 2056 2205396 82 140 199 257 316 355 394 433 472 511 665 818 931 1044 1157 1270 1453 1636 1819 2002 2160 2318410 93 153 214 274 334 375 416 457 498 539 698 857 975 1093 1211 1330 1522 1714 1906 2098 2265 2432425 105 166 228 290 352 395 438 480 523 566 731 895 1019 1142 1265 1389 1590 1791 1992 2193 2369 2545440 116 180 243 307 370 415 460 504 549 593 764 934 1063 1191 1319 1448 1658 1868 2078 2289 2474 2659455 127 193 258 323 389 435 481 528 574 620 797 973 1106 1240 1373 1507 1726 1945 2165 2384 2578 2773470 139 206 273 340 407 455 503 551 600 648 830 1011 1150 1289 1427 1566 1794 2023 2251 2480 2683 2886485 150 219 288 356 425 475 525 575 625 675 863 1050 1194 1338 1481 1625 1863 2100 2338 2575 2788 3000500 157 228 300 372 443 495 546 597 649 700 894 1089 1236 1383 1530 1677 1925 2173 2420 2668 2886 3105515 164 238 313 387 461 514 567 620 672 725 926 1127 1278 1428 1579 1730 1988 2245 2503 2761 2985 3209530 170 248 325 402 480 534 588 642 696 750 958 1166 1320 1474 1628 1782 2050 2318 2586 2855 3084 3314545 177 257 338 418 498 553 609 664 720 775 990 1205 1362 1519 1677 1834 2113 2391 2669 2948 3183 3418560 184 267 350 433 516 573 630 686 743 800 1022 1243 1404 1565 1726 1886 2175 2464 2752 3041 3282 3523575 191 277 363 448 534 592 650 709 767 825 1053 1282 1446 1610 1774 1939 2238 2536 2835 3134 3381 3627590 198 286 375 464 552 612 671 731 790 850 1085 1320 1488 1656 1823 1991 2300 2609 2918 3227 3480 3732604 205 296 388 479 570 631 692 753 814 875 1117 1359 1530 1701 1872 2043 2363 2682 3001 3320 3578 3836

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Table 4. Tarped Broadcast Buffer Zone Distances (feet)Application Block Size (Acres)

Buffer zone distances cannot be greater than 1/2 mile (2,640 feet). If after applying applicable credits the buffer zone distances are still greater than 1/2 mile (2,640 feet) the application is prohibited.


1 2 3 4 5 6 7 8 9 10 15 20 25 30 35 4064 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25 25

112 25 25 25 25 25 25 25 25 25 25 57 88 107 125 144 163

161 25 25 25 25 25 25 25 25 25 25 88 150 188 225 263 300

200 25 40 55 70 85 95 105 115 125 135 215 295 353 410 463 515

240 25 54 83 111 140 160 180 200 220 240 340 440 515 590 658 725

281 25 68 110 153 195 225 255 285 315 345 465 585 678 770 855 940

321 25 81 138 194 250 290 330 370 410 450 588 725 838 950 1050 1150

361 45 113 180 248 315 361 407 453 499 545 705 865 995 1125 1245 1365

401 65 143 220 298 375 428 481 534 587 640 820 1000 1150 1300 1438 1575

442 85 174 263 351 440 499 558 617 676 735 938 1140 1308 1475 1633 1790

482 100 200 300 400 500 565 630 695 760 825 1050 1275 1463 1650 1825 2000

522 131 238 344 450 556 626 696 766 836 906 1156 1406 1616 1825 2019 2213

563 163 275 388 500 613 688 763 838 913 988 1263 1538 1769 2000 2213 2425

601 194 313 431 550 669 749 829 909 989 1069 1369 1669 1922 2175 2406 2638

Table 5. Deep Untarped Buffer Zone Distances (feet)Application Block Size (Acres)

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The buffer zone distances for MBC-33 applications may be reduced by the percentages listed below. Credits may be added, but credits cannot exceed 80%. Also the minimum buffer zone distance is 25 feet regardless of buffer zone credits available.

See www.tarpcredits.epa.gov for a list of tarps that have been tested and determined to qualify for buffer reduction credits. Only tarps listed on this website qualify for buffer reduction credits.15% reduction in buffer zone distance, IF potassium thiosulfate (KTS) is applied at a minimum rate of 300 pounds per acre. 10% reduction in buffer zone distance, IF the organic content of the soil in the application block is 1% - 2%; a 20% reduction in buffer zone distance, IF the organic content of the soil in the application block is >2% - 3%; and a 30% reduction in the buffer zone distance, IF the organic content of the soil in the application block is >3%. 10% reduction in the buffer zone distance, IF the clay content of the soil in the application block is greater than 27%.

Examples of Buffer Zone Calculations with Credits Applied If the buffer zone is 50 feet and the application qualifies for a buffer zone reduction credit since the soil organic content is 1.5%, then the buffer zone can be reduced by 10%, i.e., reduced by 5 feet based on the following calculation: 50 feet – (50 feet x 10%) = 45 feet.

If the buffer zone is 50 feet and the application qualifies for two buffer zone credits since the soil organic content is 1.5% and the clay content is greater than 27%, then the buffer zone can be reduced by 20% (10% organic content credit + 10% clay content credit), i.e., reduced by 10 feet based on the following calculation 50 feet - (50 feet x 20%) = 40 feet.


Posting of a is required unless there is a physical barrier that prevents bystander access to the buffer zone. Buffer Zone signs must be placed along or outside the perimeter of the buffer zone, at all usual points of entry and along likely routes of approach from areas where people not under the owner’s control may approach the buffer zone. o Some examples of points of entry include, but are not limited to, roadways, sidewalks,

paths, and bike trails. o Some examples of likely routes of approach include, but are not limited to, the area

between a buffer zone and a roadway, or the area between a buffer zone and a housing development.

o When posting, the certified applicator supervising the application must ensure compliance with all local laws and regulations.

Buffer Zone signs must meet the following criteria: o The printed side of the sign must face away from the application block toward areas from

which people could approach. o Signs must remain legible during the entire posting period and must meet the general

standards outlined in the WPS for sign size, text size, and legibility (see 40 CFR §170.120).

o Signs must be posted no sooner than 24 hours prior to the start of the application and remain posted until the buffer zone period has expired.

o Signs must be removed within 3 days after the end of the buffer zone period. o Buffer Zone signs which meet the criteria above will be provided at points of sale for

applicators to use. Templates may be downloaded from http://www.epa.gov/pesticides/reregistration/soil_fumigants/index.htm.

o The Buffer Zone signs must contain the following information: “Do Not Walk” symbol DO NOT ENTER/NO ENTRE, Methyl Bromide Fumigant [MBC-33 SOIL FUMIGANT] BUFFER ZONE, contact information for the certified applicator in charge of the fumigation

Exception: If multiple contiguous blocks are fumigated within a 14-day period, the entire periphery of the contiguous blocks’ buffer zones may be posted. Buffer Zone signs must be posted no sooner than 24-hours prior to the start of the first application. The signs must remain posted until the last buffer zone period expires, and signs must be removed within 3 days after the buffer zone period for the last block has expired.

Difficult to evacuate sites are pre-K to grade 12 schools, state-licensed daycare centers, nursing homes, assisted living facilities, hospitals, in-patient clinics, and prisons.

No fumigant application with a buffer zone greater than 300 feet is permitted within 1/4 mile (1,320 feet) of difficult to evacuate sites unless the site is not occupied by children from state-licensed day care centers, students (pre-K to grade 12), patients, or prisoners during the application and the 36-hour period following the end of the application. No fumigant application with a buffer zone of 300 feet or less is permitted within 1/8 mile (660 feet) of difficult to evacuate sites unless the site is not occupied by children from state-


licensed day care centers, students (pre-K to grade 12), patients, or prisoners during the application and the 36-hour period following the end of the application.

If the buffer zone is 25 feet, then the Emergency Preparedness and Response Measures are not applicable.

The certified applicator must either follow the directions under the Fumigant Site Monitoringsection or follow the directions under the Response Information for Neighbors section if:

the buffer zone is greater than but less than or equal to , and there are residences or businesses within from the outer edge of the buffer zone, or the buffer zone is greater than but less than or equal to , and there are residences or businesses within from the outer edge of the buffer zone, or the buffer zone is greater than but less than or equal to , and there are residences or businesses within from the outer edge of the buffer zone, or the buffer zone is greater than or the , and there are residences or businesses within from the outer edge of the buffer zone.

NOTE: Fumigant Site Monitoring is ONLY required if the Emergency Preparedness and Response Measures are triggered AND directions from the Response Information for Neighbors section are not followed.

From the start of the application until the buffer zone period expires, a certified applicator or handler(s) under his/her supervision must:

Monitor for sensory irritation in areas between the buffer zone outer perimeter and residences and businesses that trigger this requirement. Monitoring for sensory irritation must begin in the evening on the day of application and continue until the buffer zone period expires. Monitor a minimum of 8 times during the buffer zone period, including these periods: - 1 hour before sunset, - during the night, - 1 hour after sunrise, and - during daylight hours.

Implement the emergency response plan immediately if a handler monitoring experiences sensory irritation.

NOTE: Response Information for Neighbors is ONLY required if the Emergency Preparedness and Response Measures are triggered AND directions from the Fumigant Site Monitoring section are not followed.

The certified applicator supervising the application must ensure that residences and businesses that trigger the requirement have been provided the response information at least

before the application starts. The information provided may include application dates


that range for no more than . If the application does not occur when specified, the information must be delivered again.

Information that must be included: The location of the application block. Fumigant(s) applied including the active ingredient, name of the fumigant product(s), and the EPA Registration number. Contact information for the applicator and property owner. Time period in which the application is planned to take place (must not range more than 4 weeks). Early signs and symptoms of exposure to the fumigant(s) applied, what to do, and who to call if you believe you are being exposed (911 in most cases). How to find additional information about fumigants.

The method used to share the response information for neighbors can be accomplished through mailings, door hangers, or other methods that will effectively inform the residences and businesses within the required distance from the edge of the buffer zone.

If your state and/or tribal lead agency requires notice, informati

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